The UK has approved a targeted update to Norfolk Vanguard’s development consent, creating a flexible route to fund habitat compensation if seabed debris proves too scarce to remove at scale. The non‑material change, in force from 19 December 2025, allows a Marine Recovery Fund payment to substitute for any shortfall in debris clearance linked to cable works in the Haisborough, Hammond and Winterton Special Area of Conservation (HHW SAC). It sits alongside existing monitoring and sign‑off requirements rather than replacing them.

This move draws on new national rules. Section 292 of the Energy Act 2023 enables one or more Marine Recovery Funds to channel developer finance into strategic, science‑led compensation for unavoidable offshore wind impacts on protected sites. Secondary legislation made in November 2025 set the framework for how such funds operate across the UK’s waters.

Why change now? In July 2024 the Secretary of State approved a revised Benthic Implementation and Monitoring Plan for the Norfolk projects after evidence showed very low densities of seabed debris within the HHW SAC. Natural England supported looking beyond the SAC boundary for recovery efforts and flagged that debris removal alone may not offset disturbance and loss of Annex I sandbank and reef features - a practical challenge the new Order now anticipates.

Under the amendment, the undertaker can apply to make a Marine Recovery Fund payment where the required area of debris cannot be fully removed. The Secretary of State must be satisfied the approach is acceptable in principle and that Defra or the designated fund operator has confirmed the fund can be used, including a quantified sum. Payment in full, or entry into an agreed instalment contract with the first instalment paid, can discharge the remaining project‑level compensation duties for this measure.

Safeguards are explicit. If the Marine Recovery Fund route is taken, no cable installation may proceed within the HHW SAC until an implementation and monitoring plan is approved by the Secretary of State and the developer’s compensation obligations have been formally discharged in writing. The adaptive pathway is therefore conditional, not automatic.

Oversight tightens as well. Results from monitoring must be submitted at least annually to the Secretary of State, the Marine Management Organisation (MMO) and the relevant statutory nature conservation body. If evidence shows the measures are not working, the developer must bring forward fixes and deliver them once approved. This keeps an evidence loop at the centre of decision‑making.

The Order also recognises that Norfolk Vanguard shares a cable corridor with Norfolk Boreas. Where impacts - and therefore compensation - are shared, the proportion to be delivered by each scheme must be set out, avoiding double‑counting while maintaining ecological outcomes. That allocation principle has been acknowledged previously in the Secretary of State’s decisions on the benthic plan.

For context, HHW SAC covers about 146,759 hectares off the north‑east Norfolk coast. It protects Annex I ‘sandbanks which are slightly covered by sea water all the time’ and areas of biogenic reef formed by the tube‑building ross worm Sabellaria spinulosa - habitats that support rich communities of marine life and are sensitive to disturbance.

Policy infrastructure is now in place to make the fund route workable. Defra’s guidance, published on 17 December 2025, explains the application and charging process for Marine Recovery Fund access, including banded reservation fees and the requirement to secure statutory nature conservation body advice before purchase. The government’s consultation response also frames the Fund as a way to speed consenting while maintaining environmental protections.

For developers and communities, the signal is clear: design out impacts first, deliver project‑level measures where they are practical and effective, and use the Marine Recovery Fund as a back‑up when evidence shows site‑specific actions cannot achieve the required lift. Done well, this blend should keep Norfolk’s offshore wind build on track while directing real money and monitoring effort to the places that need recovery most.